Aena

Aena describes its governance model (section starting page 9). Aena S.M.E., S.A. is a state-owned listed company, 51% held by ENAIRE and 49% free float, listed since 2015 and part of the IBEX-35. The highest governing bodies are the Annual General Meeting and the Board of Directors, supported by four specialised committees: Audit Committee, Appointments, Remuneration and Corporate Governance Committee, Sustainability and Climate Action Committee, and Executive Committee, plus an Executive Management Committee. At 31 December 2024 the Board had 15 members, 46.67% women (7 of 15), average age 54.9 years, with 7 independent and 6 nominee directors and a Lead Independent Director. The Chairman and CEO is Mr. Maurici Lucena Betriu. The report details director classification rules, independence criteria, the Board Selection Policy, a 40% least-represented-sex target, annual external evaluation, and that the Board held 13 meetings in 2024 with 98.97% attendance. The Executive Management Committee comprises the Chairman-CEO, Executive Vice Chairman and eight directors, 60% women.

Under Governance of sustainability (from page 19), Aena explains how sustainability matters reach its bodies. The Board of Directors promotes and ensures implementation of the Sustainability Policy, and prepares, publishes and updates the Climate Action Plan and annual progress reports, aligned with TCFD recommendations and submitted to a consultative vote by the Annual General Meeting. Each Board committee has specific sustainability responsibilities, with the Sustainability and Climate Action Committee supporting delivery of the 2021-30 Sustainability Strategy. Aena has appointed a Chief Green Officer to embed sustainability into strategic and operational decisions, supported by an internal cross-functional working group. In 2024 the Board addressed ESG matters including the 2023 sustainability report, the Climate Action Plan update, review of corporate policies, the advance of the Net Zero commitment, a Power Purchase Agreement, and the 2024 double materiality analysis. The Sustainability and Climate Action Committee meets quarterly. UK (London Luton, via the SusCo chaired by the Chief Green Officer) and Brazil (Northeast Brazil Airport Group) have their own local sustainability governance.

Aena explains how sustainability performance links to incentive schemes (from page 21). In Spain, remuneration is constrained by public-sector rules (Royal Decree 451/2012 and related orders), so Aena Spain has no discretion over director remuneration under the Corporate Enterprises Act. Despite this, variable pay for Senior Management depends on achieving company objectives that include a sustainability objective weighted at 25%. For directors, a variable supplement (maximum 60% of basic remuneration) depends on company objectives that include sustainability objectives such as developing the Climate Action Plan, weighted 25% out of 100% for the Chairman-CEO and 25% out of 50% for the Executive Vice President in 2024. A performance management system evaluates employees at least semi-annually against company, team and personal objectives, with results linked to compensation. 100% of the workforce in Spain participates. The Board annually approves company and management-team objectives and reviews achievement.

The statement on due diligence (page 22) describes procedures to identify, prevent, mitigate and remedy potential adverse effects on human rights and the environment across operations and the value chain, using internal and external references such as the consolidated management report and the Group risk map. The process follows the three pillars of the UN Guiding Principles (protect, respect and remedy) and includes risk identification and evaluation, prevention and mitigation measures, and complaint mechanisms. The Sustainability and Climate Action Committee, together with other areas including the Appointments, Remuneration and Corporate Governance Committee, corporate and operational areas, Audit Department, Compliance and Legal Affairs, and the Innovation, Sustainability and Customer Experience Department, oversees compliance, supported by the complaints channel. A double materiality assessment aligns identified risks with priorities. A table maps the core elements of due diligence to reporting sections, referencing ESRS 2 GOV-2, SBM-2, IRO-1 and MDR disclosures. Aena also describes due diligence for ethical and financial risks and for third parties.

Aena describes its risk management and internal controls over sustainability reporting (from page 24). The Group has a Risk Control and Management System based on the Risk Control and Management Policy (updated December 2024), built on ISO 31000 and COSO III and aligned with the Corporate Enterprises Act and CNMV good governance code and Technical Guide 1/2024. The methodology is a cyclical process: risk identification, assessment, management, reporting and monitoring, updating, and supervision. All risks are prioritised in the Corporate Risk Map, updated annually by the Executive Management Committee, reviewed by the Audit Committee and approved by the Board. Roles are defined for the Board, Audit Committee, Corporate Divisions and the independent Internal Audit Division. An Internal Control System for Sustainability Information is under development, alongside ICFR (ISAE 3000 certified) and other systems. In 2024 the Risk Map maintained 15 risk categories, and 11 risk-management training activities were run (six in Spain, five in Brazil).

Aena describes its strategy, business model and value chain (from page 34). Aena operates 46 airports and two heliports in Spain, and through Aena Internacional participates in 33 airports abroad (UK, Brazil, Mexico, Jamaica, Colombia). In 2024 total airports in Spain, UK (London Luton) and Aena Brazil handled 369 million passengers (up 8.5%), 3,203.7 thousand aircraft movements (up 7.1%) and 1,421,638 tonnes of cargo (up 18.1%). Comparative 2023 to 2024 data is given for Spain, UK and Brazil. Operations are split into Airport, Real estate services, SCAIRM and International segments. The 2022-26 Strategic Plan, updated in 2024, positions sustainability as a foundational pillar; the 2021-30 Sustainability Strategy has five strategic programmes and 16 lines of action aligned with the SDGs, supported by about 750 million euros of investment. UK uses the 2024-27 Responsible Business Strategy and Brazil approved its Climate Action Plan in 2024. The upstream value chain covers works, services and supply suppliers; downstream covers aeronautical and non-aeronautical operations and investments.

Aena describes the interests and views of stakeholders (from page 44). Engagement rests on transparency, dialogue, trust-building and shared value, formalised through the Stakeholder Relations Policy, Code of Conduct, integrated management policy and Sustainability Policy, approved and supervised by the Board with monitoring by the Appointments, Remuneration and Corporate Governance Committee. Stakeholders are identified, segmented and prioritised using tools including the Integrated Quality, Environmental and Energy Efficiency Management System. A stakeholder table sets out communication tools and expectations for main groups: passengers and airlines (the most relevant), employees and units, public administration and regulatory bodies (ENAIRE, AEMET, AESA), Ministry of Defence and security forces, society and local communities/NGOs, investors and shareholders, communication media, suppliers and service providers, and general aviation. Passengers and airlines are analysed periodically via a stakeholder matrix (see chapter S4). Local engagement examples include London Luton supplier workshops. The regulatory framework references the DORA airport regulation document and its consultation process.

Aena describes material impacts, risks and opportunities and their interaction with strategy and business model (from page 48). Material IROs are managed through the 2022-26 Strategic Plan, the 2021-30 Sustainability Strategy, the 2021-30 Climate Action Plan, the UK Responsible Business Strategy and the Northeast Brazil Climate Action Plan, covering own operations and the upstream and downstream value chain. The narrative covers climate change (extreme weather, GHG emissions, plus opportunities in photovoltaic energy, electrification and SAF), pollution (emissions and noise), biodiversity, human and labour rights, and consumers and end users. Material matters are presented in two tables. Impact materiality lists topics across climate change, pollution, water and marine resources, biodiversity, circular economy, own workforce, workers in the value chain, affected communities, consumers and end users, and business conduct, each with value-chain location, negative/positive, actual/potential and time horizons. Financial materiality lists risks and opportunities for climate change, affected communities and consumers and end users. Aena states the financial effect of these IROs in the year was considered minimal, with no significant changes versus 2023.

Aena describes its double materiality process (from page 50). In 2024 the Group carried out a double materiality exercise to identify, evaluate, prioritise and determine the materiality of actual and potential, positive and negative impacts, risks and opportunities across short, medium and long term. The approach follows ESRS 1, ESRS 2 (SBM-2 and SBM-3) and the EFRAG Implementation Guidance, covering Spain, Brazil and the UK (Luton) and the whole value chain. It was carried out in four phases: Contextualisation (value chain, critical customers and suppliers, regulatory environment, key assets, stakeholders, and internal and external sources including TCFD, CDP and TNFD references); Identification (linking IROs to ESRS 1 AR 16 topics, with 18 stakeholders consulted via interviews and group sessions); Evaluation (impact materiality by magnitude, scope and irremediability, plus probability for potential impacts, and financial materiality by financial effect and probability based on the risk map and climate risk analysis, using short-term of 1 year, medium of 1-5 years and long of over 5 years); and Determination (materiality thresholds). Results were validated by corporate areas and reviewed by the management committee, the joint sustainability and audit committee, and the Board.

Aena lists the ESRS Disclosure Requirements covered by its sustainability statement in an index (from page 55) that maps each DR to its page number. It covers ESRS 2 general disclosures (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and the topical standards E1 climate change, E2 pollution, E3 water and marine resources, E4 biodiversity and ecosystems, E5 resource use and circular economy, S1 own workforce, S2 workers in the value chain, S3 affected communities, S4 consumers and end-users, and G1 business conduct, together with the relevant ESRS 2 SBM-3 and IRO-1 disclosures embedded in each topical chapter and a reference to Act 11/2018. The report also identifies datapoints not included because they are not applicable to Aena's activity or not material (for example certain E4 IRO-1 items), providing the phased-in and disclosure-coverage view required by IRO-2.

Aena's transition plan is the Climate Action Plan 2021-2030, approved by the Board and put to a consultative Shareholders' Meeting vote in 2021, covering Aena S.M.E., S.A. and SCAIRM and aligned with the ACI EUROPE Net Zero initiative (net zero for controlled operations by 2050). Aena Spain brought its Scope 1 and 2 Net Zero commitment forward to 2030, ten years early, aligned with the Paris Agreement 1.5C goal. Financial resources for the Climate Action Plan in Spain over 2021-2030 total 550 million euros, within a 750 million euro Sustainability Strategy included in the DORA 2022-2026 regulatory document. The plan targets carbon neutrality in Scopes 1 and 2 by 2026 and 19 carbon-accredited airports covering over 94% of network GHG emissions. London-Luton Airport targets net zero by 2040 (Responsible Business Strategy 2024-2027, 31 ambitions), and Aena Brazil's Climate Action Plan 2024-2040 (about 6 million euros, ANB and BOAB) targets carbon neutrality in Scopes 1 and 2 by 2035 and Net Zero by 2040. Group-wide, Aena commits via SBTi to net zero across the value chain (Scopes 1, 2 and 3) by 2050. Resource allocation used transition climate scenario analysis. Aena does not carry out coal, oil or gas activities and is not excluded from EU Paris-aligned Benchmarks.

Aena discloses policies for climate change mitigation and adaptation across the Group. In Spain, the commitment is set out in the Integrated Management Policy and the Sustainability Policy. The Sustainability Policy explicitly addresses climate change mitigation and adaptation as well as energy efficiency, while the Integrated Management Policy covers the use of renewable energy and other aspects. London-Luton Airport has its own Environmental Policy, aligned with the Group's Integrated Management Policy, which treats climate change mitigation and adaptation as a main aspect, and its Responsible Business Strategy 2024-2027 establishes principles of energy efficiency and use of renewable energy. Aena Brazil likewise has an Integrated Management Policy and a Sustainability Policy aligned with Group commitments. These policies aim to maximise positive impacts and minimise negative impacts across the value chain, including managing natural capital and reducing the carbon footprint. Further detail on minimum disclosure requirements (MDR-P) is provided in the Environmental policies section.

Actions follow the Climate Action Plans (PACs) of Aena Spain, UK and Brazil, organised into programmes. The Carbon Neutrality programme aims to make Aena Spain carbon neutral by 2026 and reach ACI EUROPE Net Zero by 2030 (2040 for London-Luton and Brazil). All electricity at the Spanish network and London-Luton comes from certified 100% renewable sources; Aena Brazil reached 76% in 2024 and targets 100% by 2027. The Photovoltaic Plan could reach 51% self-supply versus 2019 consumption by 2029, and London-Luton targets 25% on-site renewable electricity by 2026. In 2024 Spain achieved 51% LED lighting replacement in terminals (target 100% by 2026); Brazil targets 100% LED by 2027. Fleet electrification reached 52% of cars and vans in Spain and 88% at London-Luton in 2024. Because the expected Scope 1 and 2 reduction was surpassed (reaching 70%), no voluntary offset credits were required in 2024. Scope 3 actions include promoting Sustainable Aviation Fuel (SAF), electrifying ground handling, 4,347 EV charging points installed across Spain, 400 Hz gate power with 100% renewable guarantee of origin, and A-CDM at five airports. Brazil plans carbon credits to reach neutrality by 2035.

Targets align with the Paris Agreement and an SBTi commitment to net zero across the value chain (Scopes 1, 2 and 3) by 2050. Aena Spain (base year 2019, 136,630.5 tCO2e Scope 1 and 2 in 2019) targets carbon neutrality by 2026 (reducing Scope 1 and 2 by 82% versus 2019 and offsetting the remaining 18%) and Net Zero by 2030 using IEA scenarios. Other Spain targets: Level 4+ ACA accreditation for 19 airports by 2026; Photovoltaic Plan reaching 51% by 2029 versus 2019 (952 GWh/year); a PPA from 2026 covering 15% to 20% of consumption; maintaining 100% renewable grid electricity with guarantees of origin (60% in 2019); 100% renewable thermal energy by 2030; energy consumption per passenger cut 9% by 2030 versus 2019 (4.44 kWh/pax in 2019); and 26% fleet electrification by 2026. London-Luton (base year 2019) targets Net Zero by 2040 (about 300 tCO2e residual). Aena Brazil (base year 2023) targets carbon neutrality by 2035 and Net Zero by 2040. The 2023 Updated PAC Report was approved with 96% shareholder votes in favour. A table shows 2024 Spain reductions of 44% (Scope 1) and 76% (Scope 2) versus 2019.

Total consolidated energy consumption in 2024 was 4,851,980 GJ (1,347,783 MWh), up from 4,676,421 GJ in 2023. Of the 2024 total, renewable energy consumption was 3,856,131 GJ (1,071,156 MWh) and non-renewable was 995,849 GJ (276,627 MWh). The renewable share of total energy was 79.50% and the fossil share 20.50%, with no nuclear consumption. By country in 2024, Spain consumed 4,346,195 GJ, the UK 152,700 GJ and Brazil 353,085 GJ. Fossil fuel consumption included crude oil and petroleum products (41,739.34 MWh) and natural gas (34,071.72 MWh); renewable sources included purchased renewable electricity and heat (1,057,837.90 MWh) and self-generated non-fuel renewable energy (8,078.70 MWh). Electricity at the Spanish network and London-Luton is 100% renewable; Aena has purchased 100% renewable electricity since 2020. Energy intensity for high climate impact sector activities per net revenue was 0.00023 MWh per monetary unit in 2024, down 9% from 0.00026 in 2023. Renewable facilities in Spain (2024) generated 8,169.98 MWh, mostly solar photovoltaic (6,416.08 MWh) plus wind and geothermal.

For 2024, total consolidated gross GHG emissions were 4,464,159.40 tCO2eq location-based and 4,377,281.52 tCO2eq market-based (up 5% and 3% versus 2023 respectively). Scope 1 (direct) was 17,690.49 tCO2eq (Spain 12,668.16, UK 1,911.07, Brazil 3,111.26). Scope 2 market-based was 28,871.34 tCO2eq (Spain 27,717.61 from heating and cooling; UK 0.00; Brazil 1,153.73), while Scope 2 location-based was 115,749.22 tCO2eq. Scope 3 totalled 4,330,719.69 tCO2eq (Spain 3,468,233.43, UK 348,055.36, Brazil 514,430.90). The largest Scope 3 categories were Category 11 use of products sold (3,306,941.29), Category 9 downstream transport (452,497.80), Category 1 goods and services (340,343.94) and Category 2 capital goods (149,762.42); categories 4, 10, 12, 13 and 14 are excluded as not applicable. In 2024 only 4,908 tCO2 were subject to the EU ETS, representing 28% of Group Scope 1 emissions. GHG intensity per net revenue in 2024 was 0.00077 tCO2 per euro location-based and 0.00076 market-based (down 10.2% from 0.00085 in 2023). Emissions follow the GHG Protocol with an operational control approach.

Aena states that the Group does not carry out GHG removals or GHG mitigation projects financed through carbon credits.

Aena states that the Group does not have an internal carbon pricing system.

For anticipated financial effects from material physical and transition risks and potential climate-related opportunities, Aena states that the Group welcomes the phase-in provision (moratorium) set out in Appendix C of ESRS 1 of the CSRD. Related to this, the E1-6 disclosure notes that for significant amounts of assets and net revenues with material physical risk, and for assets, liabilities and net revenues with material transition risk, readers should see Note 3.4 of the consolidated financial statements. Elsewhere the report states that the impact of climate-related risks and opportunities on the Group's financial situation and performance in the fiscal year is considered minimal, with no significant changes perceived in the values of assets and liabilities.

Aena states its commitment to improving air quality is set out in its Sustainability Policy and its Policy on Integrated Quality, Environmental, Energy Efficiency and Occupational Health and Safety, applicable across the Group. These policies ensure conformance for at least the pollutants nitrogen oxides (NOx), sulphur oxides (SOx), carbon monoxide (CO), non-methane volatile organic compounds (NMVOC) and particulate matter (PM10 and PM2.5), and are aligned with the Sustainability Strategy 2021-2030. Scope covers own operations and third-party activities at all network locations. Monitoring is the responsibility of the Board of Directors, supported by the Sustainability and Climate Action Committee. In 2024, London-Luton Airport updated its Energy and Environmental Policies in line with ISO 50001, ISO 14001, GRESB and Airport Carbon Accreditation Level 4. Management instruments include ISO 14001, ISO 9001, EMAS (at Menorca and Tenerife Sur), ISO 50001 energy certifications, and ISO 20906 noise monitoring accreditation, with Aena noted as the first global operator with noise data accredited to ISO 20906.

Aena describes actions on energy efficiency, renewable energy, sustainable mobility and reducing third-party emissions to cut air pollution, with prevention actions and resources reported under E1-3. Continuous automatic air quality monitoring covers SO2, NOx and particulate matter (PM10 and PM2.5). In Spain, monitoring stations operate at Adolfo Suarez Madrid-Barajas, Barcelona-El Prat, Palma de Mallorca, Alicante-Elche and Malaga airports, some integrated in regional networks, and Gran Canaria runs an annual measurement campaign. In 2024, Madrid-Barajas ran pilot decontamination tests, including a simulated vertical garden from discarded tyres treated with photocatalytic nanotechnology and a bus terminal wall treated with a photocatalytic nanogrid, which removed SOx, VOCs and NOx and eliminated NOx peaks. London-Luton has an Air Quality Strategy, has monitored PM10 since 2003, installed eight continuous real-time monitors in 2024 measuring NO2, PM10 and PM2.5, and uses diffusion tubes at 17 locations for NO2. In Brazil, ANB airports analysed aircraft and ground equipment emission simulation studies, to extend to BOAB airports in 2025.

Aena sets air quality targets through Spain's Sustainability Strategy 2021-2030, aligned with the Climate Action Plan 2021-2030, the Paris Agreement, the EU Green Deal, SDG 11 and the EU NEC Directive 2016/2284. Medium to long-term Spain targets to 2030, versus 2019 levels, are a 22% reduction in NOx emissions per passenger (from 0.60 g/pax), a 36% reduction in SOx per passenger (from 0.03 g/pax) and a 15% reduction in PM10 per passenger (from 0.05 g/pax). Reported progress in fiscal year 2024 versus 2019 shows a 70% reduction in NOx per passenger, a 32% reduction in SOx per passenger and a 70% reduction in PM10 per passenger. London-Luton has no quantitative targets, only qualitative ones set against UK law and WHO recommendations, aiming to implement an air quality action plan. In Brazil, a short-term qualitative target is to improve and extend measurement to BOAB airports, with a Climate Action Plan approved in 2024 by Aena Brazil's Board covering both ANB and BOAB subsidiaries.

Aena discloses air pollution emissions of NOx, SOx, CO, NMVOC, PM10 and PM2.5 for 2023 and 2024, by fuel type and split across Spain, UK and Brazil, in tonnes. Total 2024 NOx was 54.87 t (Spain), 6.45 t (UK) and 9.57 t (Brazil); total SOx was 6.34 t, 0.02 t and 0.00 t; total CO was 26.43 t, 1.92 t and 3.61 t; total NMVOC was 5.69 t, 0.92 t and 0.65 t; total PM10 was 4.46 t, 0.40 t and 0.80 t; and PM2.5 was 4.28 t, 0.40 t and 0.80 t. Year on year, Spain NOx fell 18% and SOx fell 7%, while Brazil rose sharply (NOx up 156%, PM up 162%). Figures are calculated, not directly measured, using the EMEP/EEA guidebook and the US FAA Aviation Emissions and Air Quality Handbook, applying emission factors to reported energy consumption from facilities and airport equipment such as boilers, generators and fire-fighting vehicles. Pollutants follow the E-PRTR Regulation (EC) No 166/2006, excluding GHGs reported under E1.

Aena states it has not identified any material risks or opportunities related to pollution, and therefore has no financial effects related to this topic. The Company adds that it will take anticipated financial effects into account in the event it identifies any future pollution-related risks or opportunities. Material financial materiality for pollution is confirmed elsewhere as having neither material risks nor opportunities.

Aena's water commitments cover environmental protection and prevention of pollution, minimising water-related impacts across all activities, compatibility of airport activity with habitat conservation, a preventive and sustainability approach across the organisation, and sustainable management aligned with suppliers and contractors. These are reflected in the Policy on Integrated Quality, Environmental, Energy Efficiency and Occupational Health and Safety and the Sustainability Policy, aligned with the Sustainability Strategy 2021-2030, applying to all sites in Spain, the UK and Brazil. Water-stressed regions were identified using the WRI Aqueduct tool (stress above 40%, extreme and high level), covering 27 Group airports: 25 in Spain, 1 in the UK and 1 in Brazil. Specific initiatives include wastewater treatment plants at Brazilian airports and discharge controls at London-Luton. Aena Spain's Strategic Water Plan 2021-2030 guides efficient use, reuse and alternative sourcing (reused, rainwater, desalinated water). Discharge management includes monitoring wastewater and rainwater to protect the Hydraulic Public Domain and Maritime-Terrestrial Public Domain, with hydrocarbon separators for contaminated rainwater; there were no breaches in fiscal year 2024.

Aena describes a comprehensive water management approach. In Spain, a 2019 diagnosis covered the full water cycle (supply, wastewater, rainwater) and led to standardised best practices such as automated leak detection, proactive maintenance and continuous consumption monitoring under the Strategic Water Plan 2021-2030. A water footprint was calculated at 100% of Spanish sites using the Water Footprint Network methodology, with systems certified to ISO 14001, ISO 9001 and EMAS. A wireless flow meter system was implemented in 2024, and desalination plants operate at high water stress airports such as Fuerteventura, Ibiza and Lanzarote. A second-use water plant at Alicante-Elche avoided 8,529 m3 of consumption in 2024, equivalent to 3.5 Olympic swimming pools. De-icing operations use glycol interceptors to prevent contamination. Airport actions include reuse from fire-fighting practices at Malaga and Valencia. At London-Luton, new water meters, low-flow faucets and dual-flush cisterns were installed. In Brazil, ANB installed high-efficiency wastewater treatment plants; Juazeiro do Norte connected its own plant for reuse, winning ACI-LAC Green Airport Recognition, and rainwater collection stations are being installed through 2024-2025.

Aena Spain's Strategic Water Plan 2021-2030 sets two voluntary strategic objectives for the period 2021-2030 applying to all sites, inside and outside water-stressed regions: reduce water consumption by 10% per passenger by 2030 versus 2019 (5% reduction by 2026), and increase the use of alternative water sources per passenger by 150% by 2030 versus 2019 (50% increase by 2026). Targets align with SDG 6 Clean Water and Sanitation. Reported 2024 progress in Spain shows total water consumption of 0.02 m3 per passenger and a 222% increase in alternative water source use since 2019, including a 155% increase in desalinated water and a 640% increase in reclaimed water, which rose from 90.6 thousand m3 in 2019 to 670.6 thousand m3 in 2024. UK consumption was 0.00817 m3 per passenger, raised by hydraulic dampening for the TCP2 car park demolition at London-Luton. London-Luton has a qualitative target to identify operations using potable water that could switch to non-potable. Brazil's targets await completion of its Sustainability Strategy in 2025. The Sustainability and Climate Action Committee oversees targets.

Aena reports total water consumption of 6,978.70 thousand m3 in 2024 (Spain 6,218.30, UK 137.85, Brazil 622.55), up from 6,673.62 thousand m3 in 2023. Consumption in water stress regions was 3,288.83 thousand m3 in 2024, about 47% of the total (48% in 2023). By source in 2024 (consolidated, thousand m3): desalination/seawater 560.86, wells/groundwater 2,125.41, drinking water from the network 4,088.14, and regenerated water purchased from third parties 204.29; reused water, rainwater and purified wastewater totalled 574.40. Water intensity was 0.0012 m3 per euro in 2024, down 9% from 0.0013, on net revenue of 5,763,531 euro. Consumption was 92% direct measurements and 8% extrapolation. Wastewater discharges by type of water in Spain in 2024 were 3,947.6 thousand m3 fresh water and 259.3 thousand m3 other water. Total consolidated discharges by destination in 2024 (thousand m3) were surface water 463.38, groundwater 70.80, seawater 0.00 and third-party water 4,105.44. Data uses standardised methodologies with meters and real-time leak detection.

Aena states it has not identified any material risks or opportunities related to water and marine resources, and therefore has no financial effects related to these aspects. The Company adds that it will take anticipated financial effects into account in the event it identifies any future water and marine resources-related risks or opportunities. Financial materiality for water is confirmed elsewhere as having neither material risks nor opportunities.

Aena assesses the resilience of its strategy and business model to physical, systemic and transitional biodiversity risks through two main types of action. First, infrastructure modification planning uses Environmental Impact Assessments of master plans and projects, Environmental Monitoring Plans and prior consultations, whose results feed into strategic and business decisions across own operations, the value chain (ESG criteria in procurement, supplier collaboration) and short, medium and long timeframes. Second, airport operations use Wildlife and Habitat Studies, Airport Wildlife Risk Assessments and Wildlife Management Programmes to keep operations compatible with biodiversity. Aena notes that although TNFD considerations were taken into account, no group-wide TNFD-based biodiversity risk analysis was conducted. The company states it has not adopted a formal biodiversity transition plan but manages resilience through these monitoring and control mechanisms. In the UK, London-Luton follows a Wildlife Strike Hazard Reduction Plan, and Aena Brazil applies Wildlife Risk Management Plans, ensuring operations remain resilient and compatible with local biodiversity.

Aena states that accelerating global biodiversity loss threatens ecosystems and is closely linked to the climate crisis. The Group commits to making airport activity compatible with the protection and conservation of natural habitats and their biodiversity through two policies applicable across the Group: the Policy on Integrated Quality, Environmental, Energy Efficiency and Occupational Safety and Health Management, and the Sustainability Policy. It also promotes adoption of this principle among collaborating companies. The Integrated Policy highlights making airport activity compatible with protecting and conserving existing natural habitats, minimising deforestation and offsetting impacts through appropriate instruments. These policies apply to Aena Group operations and the value chain. For minimum disclosure requirements on policies (MDR-P), Aena refers to its Environmental policies section.

Aena's biodiversity actions center on wildlife monitoring and control at all Spanish airports. Biological methods include trained falconry birds performing high-altitude marking flights to deter birds, applied at 33 airports and 1 heliport in Spain, plus mechanical methods such as non-lethal trapping, sound deterrents and pyrotechnics. Vegetation control and habitat monitoring are carried out in Spain and Brazil. Awareness initiatives during 2024 included exhibitions at Menorca, Albacete and El Hierro airports and awards at Malaga. A notable project is a griffon and black vulture GPS tagging study around Madrid-Barajas and Bilbao airports, tagging 85 vultures, running to mid-2027. The Radar Aviar bird-detection system is operational at Bilbao. Operating expenses on biodiversity at Aena Spain in 2024 totaled 5,503,657.70 euros. London-Luton invested 51,649.74 euros in 7 local biodiversity projects. Aena Brazil plans to replant 1,300 trees in 2025 after removing about 300 during works.

Aena's main biodiversity target is qualitative: to protect and promote local and global biodiversity over the short, medium and long term, delivered through initiatives for biodiversity protection, communication and awareness, and volunteering. No ecological thresholds or impact allocations were applied when setting targets. In Spain, indicators sit within each airport's Wildlife Program and are reviewed semi-annually, and each airport holds an annual Bird Committee meeting with wildlife management staff, the air navigation service provider, municipalities, the regional environmental department, technical experts, pilots and other stakeholders. Environmental management operates within the Operational Safety System framework across all Group airports. During 2024, the Wildlife and Habitats Study for Region de Murcia International Airport was completed, meaning these studies are now finished at all Spanish Aena airports. London-Luton aims to carry out 3 biodiversity-related actions by 2027, and Aena Brazil is developing a sustainability strategy that will define biodiversity protection targets.

In 2024 Aena carried out biodiversity conservation actions at sites within or near sensitive areas. Key impact metrics come from Adolfo Suarez Madrid-Barajas Airport. One metric is the number of birds captured and relocated outside the airport: each bird is marked with a metal ring and PVC ring, with resident birds additionally fitted with wing tags and GPS trackers. In 2024, a total of 517 birds were captured and ringed at the airport. Another indicator tracks nests and chicks on airport premises; in 2024 at Madrid-Barajas, 16 nests were managed and 40 chicks were relocated within the airport. A further metric is the number of technical awareness sessions for stakeholders and airport personnel, with Madrid-Barajas holding three such sessions in 2024. Aena notes that 18 airports and 1 heliport in Spain lie near or within Natura 2000 protected spaces, and that Natura 2000 surface within Spanish airports totals 483 hectares, plus 129 hectares in Brazil at Carajas.

Aena reports that the Group has not identified any material risks or opportunities related to biodiversity, and therefore has no anticipated financial effects related to this aspect. The company states it will take anticipated financial effects into account in the event it identifies any future biodiversity-related risks or opportunities. Aena notes that for the first year of preparation it may use the phase-in provision allowing qualitative-only disclosure for E4-6. Certain datapoints are marked not applicable due to the company's activity (including E4 IRO-1 17(e) i and ii and E4-5 38), and E4 IRO-1 17(e) iii is excluded as non-material based on the double materiality assessment. Aena also states it has not identified any material dependencies on biodiversity or ecosystem services, nor any systemic risks, in its business model.

Aena commits to promoting the circular economy in the airport environment to minimise waste generated, promote correct segregation and maximise valorisation across the value chain. This commitment is set out in the Sustainability Policy and the Policy on Integrated Quality, Environmental, Energy Efficiency and Occupational Health and Safety Management, applicable to all Group companies, and is implemented through the Sustainability Strategy 2021-2030, which defines actions to reduce waste, promote segregation and recycling and enhance energy recovery and composting in line with the waste hierarchy. London-Luton Airport's Environmental Policy incorporates circular economy and waste reduction principles across the company and on-site partners, with objectives to minimise waste and single-use plastics, maximise reuse and recycling, ensure no waste goes to landfill from standard operations, work with partners on best practices and control waste volumes to targets. These policies apply to Group operations and the value chain. Aena refers to its Environmental policies section for MDR-P.

Aena's circular economy actions focus on waste management. Contracted waste managers must aim for valorisation and recovery as the final destination, justifying any disposal. In 2024 Aena Spain updated environmental procurement clauses with stricter third-party waste criteria and reuse and recycling evaluation criteria, and is developing a waste-generation payment model to encourage valorisation and reduction. Spain's Sustainability Strategy targets a Zero Waste commitment by 2040 across measurement, waste reduction, sustainable materials, segregation and recycling, energy recovery and composting, and awareness. Actions include monitoring, selective collection via transfer plants, reuse and recycling (sludge reused as fertiliser, composting at Bilbao), collaborations with Ecoembes, Ecovidrio, ERP and the Trinijove Foundation, plastic reduction clauses, awareness signage, and innovation via the EU-cofunded LIFE-TRIPL AIR project (started June 2024, four years) involving Madrid-Barajas and Tenerife Sur with a Smart-Bin prototype. In 2024 the Group spent 9.68 million euros on circular economy operating expenses, including 8.5 million in Spain, 1.16 million in Brazil and 24,149 euros at Luton.

Aena Spain's Sustainability Strategy targets a voluntary Zero Waste goal by 2040, focused on recurrent non-hazardous waste and excluding construction and hazardous waste. The intermediate objective is to raise the share of valorised non-hazardous waste to 72% by 2030 compared with 2019. London-Luton updated its Responsible Business Strategy in 2024, targeting with concession awardees a recycling rate of 75% and a waste energy recovery rate of 25% by 2026; the airport already reached 100% valorised waste and 0% to landfill, and in 2024 exceeded its target with an 81% recycling rate and 19% waste-to-energy recovery. A track record table shows Spain's base year 2019 figure of 78.979 and actual 2024 of 39,278.97 against a 2040 objective of 0, and Luton at 74% in 2019, 72% in 2024, toward 100%. Aena Brazil's sustainability strategy, due in 2025, will set circular economy and waste objectives. An internal cross-functional working group coordinates waste management, and progress is reported to the Sustainability and Climate Action Committees.

Aena reports resource outflows through waste generated at its airport operations, monitoring total waste generated and waste reused, recycled and disposed of. Waste derives from two flows: the Group's direct activity (terminal bins, Company buildings, car parks, security filters, offices, terminal and airport cleaning, employee dining, and treatment-plant sifting) and the activity of companies and lessees at airports (food and beverage, commercial premises, third-party offices, duty-free), with the Group not managing hazardous waste from third parties. Waste is controlled by type: non-hazardous waste (comparable to domestic and commercial waste, including construction and demolition waste) and hazardous waste (used mineral oils, batteries, fluorescents, contaminated absorbents and containers, plus sanitary waste). In Spain a chronological record classifies waste by nature, selective collection points and destination (valorised through reuse or recycling, or disposed of). Data come from the Aena Spain Integrated Management System database, distinguishing more than 30 waste types. The categories of valorisation and disposal types are reported for the first time this year. Aena does not generate radioactive waste.

Aena reports that the Group has not identified any material risks or opportunities related to resource use and circular economy, and therefore has no anticipated financial effects related to this aspect. The company states it will take anticipated financial effects into account in the event it identifies any future risks or opportunities. Aena notes the first-year phase-in provision permitting qualitative-only disclosure for E5-6. Certain datapoints are excluded as not applicable given the company's activity, including E5-5 35 and E5-5 36(a) to (c), while E5-4 datapoints (resource inflows) and several E5-1 and E5-2 datapoints are excluded as non-material based on the double materiality assessment.

In 2024 the Aena Group generated 46,646.77 tonnes of total hazardous and non-hazardous waste consolidated, up from 41,152.9 tonnes in 2023. Hazardous waste totaled 1,029.48 tonnes (Spain 860.15, UK 27.8, Brazil 141.53), of which 570.68 tonnes (55.4%) were valorised and 458.8 tonnes (44.57%) disposed of. Non-hazardous waste totaled 45,617.29 tonnes (Spain 39,278.97, UK 2,181.12, Brazil 4,157.2), of which 30,434.09 tonnes (66.72%) were valorised and 15,183.2 tonnes (33.28%) disposed of. For non-hazardous waste, recycled tonnage was 4,041.36 (8.86%), reuse 23.23 tonnes (0.05%) and other valorisation 26,369.5 tonnes. Non-hazardous landfill was 10,795.87 tonnes (23.67% consolidated), all in Spain (27.50%), while UK and Brazil sent 0% non-hazardous waste to landfill. Incineration was 14.29 tonnes. Unrecycled waste totaled 42,511.62 tonnes, or 91% consolidated (Spain 94%, UK 19%, Brazil 100%). Aena Spain valorised 71.90% of non-hazardous waste; London-Luton reached 100% valorisation and 0% landfill.

Aena describes the policies governing its workforce across Aena Spain, London-Luton (UK) and Aena Brazil. The Code of Conduct (approved 2015, last updated 17 December 2024) sets principles of action for all employees regardless of position or location. The Human Rights Policy (approved 2020, amended 17 December 2024) commits to equal opportunity, non-discrimination, occupational health and safety and the right to collective bargaining, and applies to the parent company and all subsidiaries. Other relevant policies include the Sustainability Policy, Risk Control and Management Policy, Stakeholder Relation Policy and, in Spain, a Digital Disconnection Policy developed through collective bargaining. London-Luton has its own Code of Conduct, Recruitment and Selection Policy and Statement on Modern Slavery. Policies are aligned with the UN Global Compact, UN Guiding Principles on Business and Human Rights, OECD Guidelines and ILO declarations. Senior Management and the Board oversee policies, supported by committees. In 2024, 100% of employees were offered training on non-discrimination, diversity and harassment prevention.

Aena maintains ongoing dialogue with its workforce directly and through employee representatives, including collective bargaining, periodic committee and work-team meetings and consultation sessions. In Spain the main channels are the SAP SuccessFactors employee portal, an intranet with more than 30 themed portals, email, the weekly Aena 360 magazine, local channels, joint committees and a National Trade Union Coordinator. At London-Luton in the UK, a new internal social-network platform (Yammer), weekly newsletters, surveys and the Engage Co: Lab project support engagement, and surveys have been conducted on human rights and working conditions. In Aena Brazil, channels include Aena Brazil Comunica, the Estamos Conectados programme and the monthly Aena Brazil 360 magazine. To gather views, including from vulnerable groups, Aena conducts periodic psychosocial risk assessments, measures an annual engagement rate, provides diversity and inclusion training, relies on union representation and runs specific programmes for people with disabilities. Freedom of association is regulated through Spanish law and the Collective Agreement, UK law via Unite the Union, and in Brazil through an agreement with the SINA union.

Aena reports that its double materiality analysis found no material negative impacts on the workforce, but it maintains proactive mechanisms to prevent and remediate any actual impacts. These include a Regulatory Compliance System, Prevention and Action Protocols against workplace and sexual harassment (with psychological support and workplace changes for complainants), data protection measures under an Information Security Policy, and employee climate surveys. Employees can raise requests or complaints through a suggestion box available in Spain and the UK, other channels described in S1-2, and the human resources unit at each workplace. In Spain the Collective Agreement establishes several joint committees where trade unions and worker representatives participate, including the State Trade Union Coordinator, and joint committees on Training, Promotion and Recruiting, Equality, Social Action, plus the State Health and Safety Committee and an Interpretation, Monitoring, Conciliation and Arbitration Committee. Employees can also report human rights violations through channels described in section G1-1.

Aena describes actions taken in 2024 to advance positive workforce impacts across secure employment, fair wages, work-life balance, equality and training. In Spain, a Social Action Programme under the collective agreement granted over 12,000 aids totalling 1.5 million euros for education, work-life balance, health and disability. A daily working-hours registration system tracks working time. On fair pay, 100% of payments were made on time, payroll discrepancies over 200 euros are reviewed, and the pay gap in Spain was 1.1%. London-Luton achieved Living Wage employer accreditation in 2023. Work-life actions include the 360 Wellness Programme, the Settlement Care Programme (4,213 uses in 2024 versus 3,282 in 2023), flexible schedules and enhanced leave. Equality actions include participation in Promociona, Proactiva and Progresa programmes, with 64% women in High Specialisation programmes against a 50% target. Health and safety and training actions are also described. Effectiveness is monitored through audits, satisfaction surveys and worker representative involvement.

Aena sets targets to monitor the effectiveness of its workforce policies and actions. On secure employment, the company measures trust and well-being through surveys; the 2024 engagement rate of the surveyed workforce stood at 82% (81% in 2023). On fair pay, Aena Spain set qualitative objectives including facilitating the remuneration audit each Equality Plan period (every four years), an annual review of the Remuneration Record for Aena and Aena SCAIRM, and reporting to and review by the Joint Committee on Equality on any gender wage gap deviations; since the 2022 base year all targets, including those for 2024, have been met on time. On diversity, Aena Spain aims to increase the presence of women in management: women on the Board were 46.7% in 2024 (target to maintain or exceed 40%), women airport directors 26.9% (target 25% by 2026) and women directors in Central Services 42.5% (target 45% by 2026). Health and safety targets set accident numbers below 58 and an incidence rate below 771.

As of 31 December 2024, the Aena Group directly employed 10,509 salaried workers (10,111 in 2023), comprising 6,510 men and 3,999 women, with none recorded as other or not reported. By country the workforce was 8,714 in Spain, 944 in the United Kingdom and 851 in Brazil. Most employees hold permanent, full-time contracts: 90.4% of contracts are fixed and 94.4% work full-time. There were 9,499 workers on fixed salaries, 998 on temporary contracts, 12 with hours not guaranteed, 9,925 full-time and 584 part-time. The temporary contract rate was 11.12% in Spain (with an adjusted figure of 6.85% excluding certain public-sector interim and respite contracts), 3.41% in Brazil and zero in the UK. During 2024, 420 people left the company, giving a staff turnover rate of 4.15% and a voluntary turnover rate of 1.97%. Aena states its entire workforce consists of salaried employees with no non-salaried workers. Turnover is broken down by age, gender and region.

Aena reports that its entire workforce consists of salaried employees who work directly for the Company, and that there are no non-salaried or non-employee workers, whether self-employed or provided by companies engaged in employment-related activities. Because of this, Aena states that the specific disclosure requirements on non-employee workers (S1-7 paragraphs 55, 56 and 57) are not considered applicable to the Company's activity. Aena notes that certain services such as passenger ground transportation, security, cleaning and passenger inspection are outsourced to contracted companies, but in those cases Aena does not maintain a direct employment relationship with, nor exercise control over, those workers. The management of impacts Aena may have on those outsourced workers is addressed instead under ESRS S2 (workers in the value chain).

In 2024, 99.70% of all salaried workers of the Aena Group were covered by a collective bargaining agreement. Within the European Economic Area, particularly Spain, 99.85% of employees were covered (99.85% in 2023), including 99.86% for Aena SME, S.A. and Aena Sociedad Concesionaria del AIRM. The workforce of Aena SME and AIRM is covered by the Aena Group Collective Agreement, which was recently updated and set to take effect in 2025, while 27 ADI employees are governed by the Offices and Offices Collective Agreement. Outside the EEA, coverage in the United Kingdom was 100% (as in 2023) and in Brazil 97.77% (down from 99.65% in 2023). Social dialogue representation in the workplace in Spain was 100%. During 2024, Aena Spain held 42 meetings, plus two additional meetings, with worker representatives to negotiate the 2nd Collective Bargaining Agreement, signed in January 2025 and pending publication in the Official State Gazette. Aena notes there is no European Works Council.

Aena reports gender diversity in senior management and age diversity across its salaried workforce. In 2024, senior management comprised 13 people, 6 women (46%) and 7 men (54%). By age, the consolidated workforce distribution in 2024 was 5.10% under 30 years old (4.62% in 2023), 53.36% aged 30 to 50 (54.78% in 2023) and 41.54% over 50 (40.60% in 2023). Additional diversity context appears elsewhere in the S1 disclosures: women represented about 37% of the Brazil workforce in 2024, exceeding the IATA target of 25% women by 2025, and Aena Spain reported women at 46.7% on the Board of Directors, 26.9% as airport directors and 42.5% as directors in Central Services. Aena also reports being recognised by the Equileap Gender Equality Report as the best company in Spain and sixth in the world for gender equality policies, and received the Ministry of Equality DIE badge.

Aena reports that at the end of fiscal year 2024 its minimum wage was higher than the statutory minimum wage in all countries where it operates and for all salaried employees. In Spain, against a legal minimum inter-professional wage of 1,134 euros per month (15,876 euros per year), the lowest salary at Aena companies was 25,433 euros for men (24,943 in 2023) and 25,224 euros for women (24,179 in 2023), which is 60% higher than the minimum for men and 59% higher for women. In the UK, the national minimum wage was 13.8 euros per hour (11.44 pounds), while the airport minimum was 15.17 euros per hour (12.58 pounds), up from 14.27 euros per hour in 2023. In Brazil, the lowest salary was 360.80 euros per month for men and 365.31 euros for women, exceeding the national legal minimum of 219.38 euros per month by 64.5% and 66.5% respectively. The minimum wage is calculated on the gross wage of the lowest remuneration category, excluding interns and apprentices.

Aena reports on social protection as part of its actions on secure employment and working conditions. All employees are entitled to maternity, paternity and adoption leave in all countries where the Group operates. In Spain, beyond public services, Aena offers additional benefits including private health insurance, life and accident insurance, a Pension Plan, and access to the Work-Life Balance Support Programme and Wellbeing 360 Programme, and has resumed Retirement Preparation Workshops. Maternity leave is fully paid with enhanced and cumulative breastfeeding leave, and paternity leave is gender-neutral, with Royal Decree-Law 6/2019 granting both parents 16 weeks of leave. In the UK, private health insurance extends to the whole family with emotional support, and a Maternity Policy grants 4 weeks of full-pay leave and up to 28 weeks of paid leave, plus up to 5 extra emergency parental leave days. In Brazil, medical and dental insurance are provided, and since 2024 a programme extends maternity leave to 180 days and paternity leave to 20 days, supported by a government tax incentive.

Aena guarantees universal accessibility in employment for people with disabilities in all countries where it operates, using an inclusive access model in recruitment and selection with adaptations for candidates with disabilities. Data collection follows each country's legal definitions: in Spain, disability means a recognised degree of 33% or more; in the UK, disability is a protected characteristic under the Equal Opportunity Act 2010 and information is only available where voluntarily provided; in Brazil, Aena works with the Enterprise-School Integration Centre for young people with intellectual disabilities. At the end of 2024, 1.65% of the Group's workforce had a disability (1.56% in 2023), totalling 173 employees (158 in 2023). By region this was 124 in Spain (1.42%), 27 at London-Luton in the UK (2.86%, up from 9 or 1.11% in 2023) and 22 in Brazil (2.59%, down from 28 or 3.52%). The Spanish figure reflects actual headcount and does not include equivalent numbers from compensatory measures approved by SEPE.

Aena reports training and skills development metrics for 2024. Across the Group, employees received 731,387 total hours of training, averaging 69.60 hours per employee: men received 484,196 hours (74.38 hours average across 6,510 employees) and women 247,191 hours (61.81 hours average across 3,999 employees). Performance appraisals were performed on 100% of employees agreed by Management, with 26% of women and 22% of men having received a performance appraisal, at one appraisal per person. In Spain, equality training reached 8,344 people (96% of the workforce), with 585 people (7%) completing the Equal Opportunities between Women and Men course. Development programmes included Persons 4.0 (867 online assessments, 224 employees in 30 editions), highly specialised programmes taught by IESE, ESADE and IE (18 executives), a coaching programme (20 participants) and the Leaders developing leaders mentoring programme (304 participants, 131 women, 43%). Aena attended 33 job fairs and holds 33 collaboration agreements with universities and educational centres.

Aena reports that its Health and Safety Management System covers 100% of employees in Spain, the UK and Brazil. For 2024 across the Group, there were 3,166 days lost due to work-related injuries, zero fatalities due to poor health, zero fatalities due to occupational accidents, zero work-related illnesses and 203 accidents at work, giving a rate of work-related injuries of 12.38 (calculated as number of accidents divided by total hours worked, multiplied by one million). The injury rate covers workplace and in-itinere accidents in Spain and Brazil, but UK in-itinere accidents could not be included as they are not required by British regulations. Against Spanish targets, the 2024 incidence rate of accidents was 621 (target 771, and 663 in 2023) and the number of accidents was 53 (target 58, and 55 in 2023). Worker training on occupational health and safety across the Group in 2024 comprised 345 training activities, 9,540 employees and 133,291 training hours. The UK system is externally audited every three years by the British Standards Institution.

Aena reports work-life balance metrics focused on family leave. In 2024, 100% of employees were eligible for family leave (parental or adoption/foster care), unchanged from 2023. The percentage of employees who took family leave was 2.15% in 2024 (2.03% in 2023). Of those taking family leave, 163 were men (162 in 2023) and 63 were women (43 in 2023). The types of leave included in the calculation are maternity (including partial, multiple and premature), paternity (including large family, multiple and partial), paternal rest, and adoption or fostering (including multiple and international). Aena also describes supporting work-life balance measures such as the 360 Wellness Programme, the Settlement Care Programme (4,213 uses in 2024), flexible clock-in and clock-out schedules, shortened summer workdays, additional leave days by seniority, and, in Spain, a Digital Disconnection Policy developed through collective bargaining. London-Luton offers flexible working and up to 5 extra emergency parental leave days, and Aena Brazil provides flexible working and reduced hours for pregnant women.

Aena reports the gender pay gap and the annual total remuneration ratio, calculated per CSRD methodology using average gross hourly wages, with 2023 recalculated for comparability. In 2024 the total wage gap was 1.1% in Spain (down from 1.6% in 2023), 18.6% in the United Kingdom (18.4% in 2023) and 15.7% in Brazil (14.6% in 2023). By category in Spain, the gap ranged from -0.4% for Senior Management to 3.9% for Coordinators and Technicians. Aena attributes the Spanish gap mainly to female underrepresentation in groups such as Firefighting and Maintenance, and the UK and Brazil gaps to the difficulty of attracting and retaining female talent in the sector. The annual remuneration ratio, defined as the total annual remuneration of the highest-paid person divided by the median for all other employees (using Purchasing Power Parity), was 5.10 in Spain, 27.64 in the UK, 44.65 in Brazil and 24.25 for the total. In Spain the Remuneration Record is compiled under Royal Decree 902/2020 on equal pay.

Aena reports data on cases investigated related to human rights issues such as discrimination or harassment, reported through employee complaint channels and other internal channels linked to the sub-sub-topics of ESRS S1. The number of cases investigated regarding discrimination, including harassment, reported in the reference period is cross-referenced to the table in section G1-1. Aena states that in 2024 it did not find any serious human rights impacts related to its workforce in any of the cases investigated, and that it did not receive any fines, sanctions or compensation for damages as a result of complaints or claims related to discrimination, harassment or serious human rights violations during the year. These outcomes are supported by the harassment prevention and action protocols, whistleblowing channels and the joint committees described elsewhere in the S1 disclosures across Aena Spain, London-Luton in the UK and Aena Brazil.

Aena reports Board-approved policies to manage the material positive impacts on value chain workers, aligned with national and international human rights and business ethics standards. The core instrument is the Third-Party Code of Conduct, defining minimum ethical and responsible standards for suppliers, customers and professionals, covering human rights, recognised labour rights, environmental care, anti-corruption and respect for local communities. Value chain companies lacking their own code or human rights policy must formally adhere to Aena's Code of Conduct and Human Rights Policy. The Code must be expressly accepted before contracting and applies to subcontractors; airports in Brazil and the UK have their own adapted versions. The Stakeholder Relations Policy, Sustainability Policy and Human Rights Policy extend commitments on freedom of association, collective bargaining, prohibition of child labour and elimination of forced labour, with a stated rejection of modern slavery and human trafficking. London-Luton Airport adds its own Code of Conduct, Sustainability Policy, Contractor Code of Practice, Modern Slavery Statement, Whistleblowing Policy, Equal Opportunities policy and Procurement Policy.

Aena describes channels to engage value chain workers, mainly through its procurement processes. Case file managers handle information from publication onward, and a dedicated mailbox lets bidders submit queries that are published for all potential bidders. Two landing pages, the Aena Supplier Procurement Portal and the Aena Empresas Portal, plus the Public Sector Procurement Platform, publish tenders, specifications and awards. An electronic bidding platform with encrypted bids, dedicated email mailboxes, a user manual and a support centre facilitate communication with suppliers and lessees. In the UK, London-Luton uses the In-Tend Procurement Portal, its website and purchasing-team emails, with online or in-person meetings after contracting. In Brazil, airports and suppliers use emails, SharePoint sites and the SAP Ariba tool. Aena also states it seeks to understand the perspectives of vulnerable or marginalised workers, such as people with disabilities, through stakeholder dialogue, integrating social and environmental criteria into tendering. Further detail is cross-referenced to sections G1-2.

Aena states that its double materiality analysis identified no material negative impacts on value chain workers, but it describes preventive processes. Group companies provide third parties with channels to report or enquire about violations of the Code of Conduct, breaches of internal regulations and the compliance system, criminal or administrative violations, occupational health and safety matters, and possible breaches of EU law. In Spain, communications go through the Case File Manager and the Whistleblowing Channel, which serves as the primary tool for any third party, including consumers or end users, to report concerns about human rights or regulatory breaches across the Group and its value chain; equivalent channels exist in subsidiaries. Management of these channels is cross-referenced to section G1-1. Additional tools to understand supplier needs include preliminary market consultations, working groups, user committees, and monitoring of complaints, suggestions and compliments. Through these channels, needs such as clearer contractual requirements, greater transparency, equal treatment and streamlined procedures were detected.

Aena describes actions to secure positive impacts on value chain workers. In 2024, mandatory social and human rights clauses were incorporated into 100 percent of contracts. A new tender for duty-free shop spaces included ESG aspects worth 10 percent of the overall score, with social criteria such as SA 8000, ISO 45001 occupational health and safety, or AENOR gender and pay equality certificates. Aena Spain's 2nd Equality Plan includes tie-breaking criteria favouring companies with higher percentages of female employees, for the period 2022 to 2026. Internal management tools include the Internal Procurement Instructions, the Internal Commercial Procurement Standard, the Supplier Procurement Procedure manual and a technical evaluation guide. London-Luton has a Supplier Strategy 2022-2025 and a Responsible Business Strategy; Brazilian subsidiaries follow local Procurement Regulations. Aena states no severe human rights cases, such as those involving freedom of association, child labour or forced labour, were identified in supplier contracts in 2024, though two workplace harassment reports were investigated.

Aena reports that it uses qualitative indicators to monitor the effectiveness of its policies and actions relating to value chain workers, such as the inclusion of specific sustainability and quality clauses in contracts with suppliers. Further detail on the monitoring of this matter is cross-referenced to section G1-2. Aena also notes that several datapoints were excluded following the double materiality analysis on the basis that they were not material to the Company, including certain S2 SBM-3 and S2-4 datapoints, while others were treated as contextual or answered in linked datapoints. The Company does not report quantitative targets specific to value chain workers, relying instead on qualitative monitoring indicators tied to contractual clauses and its broader procurement practices.

Aena reports a framework of policies to manage impacts, risks and opportunities for affected communities, with global scope covering the Group and subsidiaries, both upstream and downstream in the value chain, and adaptable to local regulations under Board and Senior Management supervision. The Sustainability and Climate Action Committee monitors compliance and effectiveness. The Sustainability Policy commits to minimising environmental impacts with a preventive approach, especially aircraft noise management, and to maximising positive and minimising negative impacts across the value chain. The Human Rights Policy formalises the commitment to respect and protect the rights of affected communities, including indigenous peoples and vulnerable groups, and is built around three aspects: involvement (open dialogue), due diligence (continuous human rights due diligence), and repair (accessible, confidential reporting and complaints channels). On aircraft noise it commits to mitigation through noise insulation schemes and optimised operations. The Integrated Management Policy addresses quality, environment, energy efficiency and occupational health and safety, and the Stakeholder Relations Policy fosters ongoing dialogue and consensus with local communities.

Aena describes continuous, direct dialogue with affected communities, managed by dedicated areas such as the Management Office of the Noise Insulation Schemes. Engagement occurs at strategic planning and daily operations through periodic meetings and public consultations. In Spain, Joint Committees (Comisiones Mixtas), including the Ministry of Transport, the Ministry for Ecological Transition, autonomous communities, municipalities and Aena, report on acoustic easements and related action plans. In the UK, the London-Luton Airport Advisory Committee (LLACC) brings together local authorities, community groups and stakeholders and reviews quarterly and annual acoustic reports; the Luton Rising initiative promotes local economic development. In Brazil, six airports have Aviation Noise Management Committees (CGRA) preparing Noise Zoning Plans, plus public consultation processes. Interactive noise tools include WebTrack in Spain, TraVis in the UK and Ouvidoria in Brazil. Spain also uses Environmental Monitoring Committees and Noise Working Groups. Complaints channels are on corporate websites and available in local languages. In 2024, noise claims reached 756 in Spain (up from 271 in 2023), 244 claimants at London-Luton (down from 1,108), and 100 claimants in Brazil (up from 7).

Aena reports that aircraft noise is the most significant material impact near airports, and addresses it through a strategy based on the ICAO Balanced Approach to Aircraft Noise Management (adopted 2001, reaffirmed in Resolution A41-20). The approach covers reduction of noise at source (working with airlines to use quieter aircraft and noise reduction procedures), noise abatement operational procedures (optimising flight routes with the air navigation provider to avoid residential overflight and reduce night noise), land-use planning and management (reports to the Directorate General of Civil Aviation to introduce zoning that prevents noise-sensitive developments), noise insulation schemes for affected buildings, noise monitoring systems, and community engagement through periodic information sharing, public consultations and complaint resolution. These actions feed into Noise Action Plans tied to Strategic Noise Maps, which Aena Spain prepares every five years under Directive 2002/49/EC for airports with over 50,000 annual aircraft movements. During 2024 Aena Spain completed Noise Action Plans for its major airports, pending 2025 approval. In the UK, the London-Luton Noise Action Plan responds to 2006 environmental noise regulation and the Aviation Policy Framework. Aena Brazil uses noise maps to assess and mitigate impact.

Aena reports concrete actions on affected communities, focused on reducing acoustic impact while maximising social and economic benefits. In Spain, Noise Insulation Schemes (PAA) protect homes and noise-sensitive buildings such as schools, hospitals and cultural sites. During 2024 the Group completed noise insulation of 296 properties in Spain and awarded nearly 20 million euro in contracts to insulate more than 2,000 homes. It reviewed noise footprints at La Palma, Menorca, Reus, Santiago-Rosalia de Castro and Vigo, and expanded protected houses at Palma de Mallorca (4,934), Tenerife Sur (2,456) and Fuerteventura (55). The Management Office processed more than 1,700 information requests and 4,125 insulation requests, assessed 171 projects and supervised 336 completed works. London-Luton insulated 138 properties in 2024. The Group held 15 meetings on Spanish insulation schemes. Cumulatively (2000-2024 Spain, 2016-2024 UK) 29,098 properties were insulated for 366,773,541 euro. Noise Monitoring Terminals operate at 14 Spanish airports; tools include WebTrack and InsightFull (launched 2024). London-Luton hosted an Airspace Noise Week. No significant human rights incidents affecting communities were reported through the Whistleblowing Channel in 2024.

Aena reports short-term and medium to long-term aircraft noise targets. In Spain, the short term involves maintaining and improving the noise monitoring system, collaborating with ENAIRE to optimise air navigation procedures, and approving the Noise Action Plans 2024-2028 aligned with the ICAO Balanced Approach. The medium to long term implements those plans and continues Noise Insulation Schemes, aligned with EU policies including the Zero Pollution Action Plan and the Sustainable and Smart Mobility Strategy. Noise Action Plans exist for 13 major Spanish airports with over 50,000 annual movements, reviewed every five years, with targets based on Strategic Noise Maps in their 4th round. In the UK, London-Luton's Noise Action Plan 2024-2028 uses 2021 as a base year and targets reducing the daytime Noise Violation Limit for departing aircraft to 79 dB by 2026 and the nighttime limit to 78 dB by 2025, 95 percent compliance in Continuous Descent Operations, 100 percent of aircraft meeting ICAO Annex 16 Chapter 4 by 2027 and at least 75 percent classified as Chapter 14 by 2028. Aena Brazil's Sustainability Strategy, due in 2025, will set noise targets. Targets are set through public consultation with communities and authorities, and tracked via noise monitoring, insulated property counts and complaint resolution.

Aena states it has no policy dedicated exclusively to consumers and end-users (airport passengers); instead their interests are integrated into cross-cutting policies. The Human Rights Policy, approved by the Board and updated in December 2024, sets commitments to safe, accessible, quality service, non-discrimination, transparency, confidentiality and trust with customers, and integrates accessible complaints channels for reporting violations. Other governing policies include the Sustainability Policy, the Policy on Integrated Quality, Environmental, Energy Efficiency and Occupational Health and Safety Management, the Information Security Policy (aligned with ISO 27001 and Spain's National Security Scheme, covering secure processing of personal data with prevention, detection and reaction measures), and the Operational Safety Policy. Innovation is guided by the Innovation and Digital Transformation Strategic Plan 2021-2026. Policies cover upstream and downstream value chain, are supervised by the Board of Directors, and are publicly available on the corporate website. The approach addresses safety, accessibility (including reduced-mobility passengers), user satisfaction and data protection, and extends to operations in Spain, the United Kingdom (London-Luton) and Brazil.

Aena engages passengers and other users through dialogue, quality surveys and interactive devices. It uses passenger satisfaction questionnaires, boarding-gate surveys designed with a sampling plan, EMMA surveys on air-mode mobility, and annual Airline Company Surveys (ECAs). Success is measured via the Airports Council International (ACI) Airport Service Quality (ASQ) awards, based on passenger surveys; in 2024 several Aena airports won ACI awards, including Barcelona-El Prat as Best Airport in Europe (over 40 million travellers) and Palma de Mallorca (25-40 million). London-Luton was recognised by ACI in the 10-25 million category and reached its highest customer satisfaction score of 4.07, with 4 of 5 passengers rating their experience very good or excellent. Special attention is given to vulnerable groups: people with reduced mobility (PRM), non-visible disabilities (badge system) and others, supported by the free, personalised Barrier-free service and rating surveys. Aena collaborates with associations such as CERMI, FAPOE and Autism Bedfordshire. DORA II is prepared through a consultation process with airlines, the CNMC regulator and government bodies. The chatbot Oli has assisted more than 2.5 million passengers since December 2022.

Aena provides multiple channels for passengers to submit inquiries, complaints, claims, suggestions and congratulations. In Spain these include the website Procedures and Claims Portal and claims forms at airports; social media (X, Facebook, Instagram, LinkedIn) is monitored but outside the formal procedure. London-Luton in the UK offers an online feedback form and airport claims forms, aiming to respond within 48 hours via Dynamics 365. Brazil uses the Ouvidoria channel and an ombudsman, with a maximum response time of 16 days. A dedicated chat is available for people who are hard of hearing. All airports have complaint-handling procedures and dedicated passenger-service departments, internally supervised by each airport director. In Spain, DORA II indicator OTAC-01 requires at least 98% of claims to be answered within 5 business days. In 2024 the total number of complaints and claims was 15,072 in Spain (14,760 in 2023), 13,302 at London-Luton (8,343 in 2023) and 988 in Brazil (268 in 2023), for a total of 29,362 (23,371 in 2023). Categories include car parks, security services and supplementary services. Happy or Not devices collect continuous user feedback in lounges.

Aena takes action across quality, accessibility, operational disruptions, innovation, safety, security and cybersecurity. Quality is measured through ACI ASQ surveys (34 airports in Spain), Happy or Not (Spain) and Feedback Now (London-Luton) devices, with 17 DORA II quality indicators across five areas. Customer experience training reached 8,751 employees in 2024. Accessibility centres on the free, personalised Barrier-free service for reduced-mobility passengers (PRM), which received a 4.94 out of 5 average user rating; PRM requests totalled 2,613,992 in 2024 (2,230,359 in 2023). Measures include AenaMaps accessible routing, magnetic induction loops, non-visible disability badges at the 18 busiest airports, adapted toilets, and collaboration with CERMI, ONCE, FASOCIDE, Autism Bedfordshire and others. Safety and security: 83% of Spanish airports are certified under EU Regulation 139/2014; 8 security drills were conducted in 2024; new border control equipment (over 1,400 self-check-in kiosks, over 900 automatic ABC doors) was deployed. On data privacy and cybersecurity, the ISMS is certified to ISO/IEC 27001 (audited by AENOR); reported information security breaches, data breaches and affected individuals were all zero in 2024. R&D&I investment exceeded 43.7 million euros in 2024.

Aena sets quantitative and qualitative targets. On airport capacity, its investment plan aims to reach network capacity of about 348 million passengers by 2026, with per-airport and per-infrastructure utilisation targets set in DORA II Annex 2 for 2022-2026. On quality, DORA II sets overall passenger satisfaction targets: for airports with at least 100,000 passengers per year whose historical average exceeds Very Good (4), maintain perceived quality at 100% during the DORA period; if below, improve satisfaction by 1% year-on-year until reaching that value. 2024 ASQ quality-of-service-to-passengers scores (out of 5) were 4.18 in Spain, 4.07 in the UK and 4.43 in Brazil. AESA verifies compliance, with bonuses or penalties applied to charges. Accessibility targets include extending the non-visible-disability badge to all Spanish network airports and continuing accessibility days and staff training; DORA II includes a PRM satisfaction indicator. Operational disruption targets require reviewing the Business Continuity and Activity Recovery Plan at least every three years. Cybersecurity targets are qualitative, monitored via KPIs such as the BitSight rating, training completion rates and phishing click rates. Innovation targets focus on strategic partnerships, predictive analysis and improving passenger experience through tools like Oli.

Aena's corporate culture is grounded in a Code of Conduct (approved June 2015, last updated December 2024) setting principles of ethics, integrity, legality and transparency under a principle of zero tolerance for illegal behaviour, applicable to all board members, management and employees. Additional business conduct policies include a Third-Party Code of Conduct, a Regulatory Compliance Policy, an Anti-corruption and anti-fraud policy, a Business Courtesies Policy (new in 2024, aligned with international anti-bribery standards), an Antitrust Compliance Policy (new in 2024), and an Internal Whistleblower Reporting and Protection System Policy. A decentralised Regulatory Compliance System operates in Spain, the UK and Brazil, overseen by the Compliance Supervision and Control Body (OSCC) and Compliance Division, reporting to the Audit Committee. Confidential, anonymous whistleblowing channels exist in each country (Spain's online channel, UK's EthicsPoint/Navex line, Brazil's Ethics Channel) with anti-reprisal protection. In 2024, over 6,290 employees in Spain received Regulatory Compliance System training (626 in 2023); 311 employees at London-Luton took Code of Conduct training and 368 completed anti-corruption/bribery training; 592 employees trained in Brazil. In 2024 the Group completed investigation of 133 communications (22 Spain, 6 UK, 105 Brazil).

Aena manages supplier relationships through a procurement strategy integrating ESG objectives, based on the Third-Party Code of Conduct which sets minimum ethical standards under a principle of zero tolerance for illegal behaviour. Suppliers must comply with criteria on labour rights, environment and safety; contracts include sustainability and quality clauses monitored through continuous evaluation, with financial penalties or termination for non-compliance. Social, environmental and sustainability criteria are embedded in tender documents and the Guide for the Technical Evaluation of Supplier Files, with suppliers demonstrating better sustainability performance receiving higher scores. Examples include reserving contracts for special employment centres, requiring ISO 14001 and ISO 45001 certificates, sustainable handling-fleet targets (40% by 2025, 78% by 2030), and tie-breaking clauses favouring responsible practices and higher female employment (except in Brazil, which has none). Compliance is mandatory for 100% of successful bidders. Monitoring is region-specific: in Spain the File Director oversees compliance and issues conformity certificates; the UK uses service level agreements and KPIs; Brazil conducts monthly supervision and may withhold payments if compliance falls below 90%. Suppliers must adhere to the Human Rights Policy where they lack their own.

Aena prevents and detects corruption and bribery through preventive, detection and action measures within a three-lines compliance structure. Preventive measures include the Business Courtesies Policy (prohibiting giving, promising or offering courtesies to public authorities or private entities beyond acceptable limits), a complete prohibition of political contributions and of facilitation payments in all geographies, controls on sponsorship and patronage, accurate books and accounting records (banning secret accounts), and due diligence on suppliers, customers and business agents including anti-corruption clauses in contracts. Detection relies on complaints/whistleblowing channels in Spain, the UK and Brazil. Training on the Regulatory Compliance System, which includes specific anti-corruption content, was provided to the workforce, with awareness actions aimed at 100% of staff (including an International Anti-Corruption Day video campaign on the Business Courtesies Policy) and specific training for board members joining in 2024. Positions most exposed to corruption and bribery risk (management staff, directors and heads of division) were identified: 400 at-risk positions in total (315 Spain, 25 UK, 60 Brazil), of which 303 were covered by anti-corruption programmes (76% overall; Spain 69%, UK 100%, Brazil 100%).

Aena reports on confirmed incidents of corruption or bribery. The Group's preventive framework is designed to guarantee that there is no case of fraud, corruption or bribery in any of its forms. The fines and penalties table for corruption and bribery reports zero fines or penalties for cases of corruption or bribery across Spain, the United Kingdom and Brazil, with a total consolidated figure of 0 in both 2024 and 2023. Separately, in the Group's whistleblowing/complaints activity, 11 communications relating to corruption and bribery had investigations closed in 2024 (10 in Spain, 0 in the UK, 1 in Brazil); of these, in Spain 1 was investigated without measures, 4 investigated with measures executed or implemented and 5 with measures in progress, and in Brazil 1 with measures in progress. Aena states it does not report the voluntary datapoints G1-4 25(b), 25(c) and 25(d), having decided not to disclose them. No fines or penalties for confirmed corruption or bribery cases were recorded during the reporting period.

Aena reports its average payment period (APP) to suppliers, published every six months without distinguishing supplier type. In Spain the average payment period in 2024 was 26.73 days, down from 30 days in 2023. The ratio of transactions paid was 28.36 days (31 days in 2023) and the ratio of transactions pending payment was 7.23 days (15 days in 2023). Usual contractual terms in Spain are payment against certification, within a maximum of 30 days, with one fixed payment day per month; the APP is calculated using accounting balances of trade creditors in line with transparency regulations including Act 18/2022. In the United Kingdom the standard payment time is 30 days, with a payment period of 22 days in 2024 and more than 80% of invoices paid within 30 days. In Brazil, under a Supplier Payment Procedure with payments made on the 10th and 25th of each month, the APP is 45 days. There are currently no ongoing legal proceedings for late payments in Spain, the United Kingdom or Brazil.